Overview
Title
Agency Information Collection Activities: Proposed Collection Renewal; Comment Request
Agencies
ELI5 AI
The government agency called the FDIC is checking if they should continue two projects that help keep banks safe and gather feedback after checking banks. They want people to tell them if these projects are still useful and easy to do by the end of May 2025.
Summary AI
The Federal Deposit Insurance Corporation (FDIC) is seeking public comments as part of its obligation under the Paperwork Reduction Act of 1995. They are considering renewing two existing information collections: one related to the Bank Protection Act compliance and another involving Post-Examination Surveys for FDIC-supervised banks. The FDIC wants input on the necessity and efficiency of these collections and suggestions to enhance them or reduce the burden on respondents, with comments due by May 27, 2025.
Abstract
The FDIC, as part of its obligations under the Paperwork Reduction Act of 1995 (PRA), invites the general public and other Federal agencies to take this opportunity to comment on the renewal of the existing information collections described below (OMB Control No. 3064-0095 and -0218).
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Sources
AnalysisAI
The Federal Deposit Insurance Corporation (FDIC) has invited public comments on the renewal of two existing information collections as part of its compliance with the Paperwork Reduction Act of 1995. This notice focuses on procedures related to the Bank Protection Act compliance and post-examination surveys for FDIC-supervised banks. The FDIC's goal is to assess whether these information collections are necessary, efficient, and if there are ways to improve or reduce the burden on respondents. Comments are due by May 27, 2025.
General Summary
The FDIC is requesting feedback on two specific areas:
Procedures for Monitoring Bank Protection Act Compliance: This involves recordkeeping requirements to ensure banks adhere to standards protecting against financial crime. The focus is on the bank's internal security measures and reporting to their board of directors.
Ombudsman Post-Examination Surveys: These surveys evaluate bankers' opinions about FDIC examinations' effectiveness and identify ways to enhance the process. Respondents can provide feedback about examination quality and suggest improvements.
Significant Issues and Concerns
While the FDIC sets the stage for feedback, the document has some areas lacking clarity:
The specifics behind the "9,670-hour decrease in burden" for the Bank Protection Act procedures are not fully detailed. The document mentions an elimination of certain respondents and revised time estimates but does not break down these elements.
Similarly, the "251-hour decrease in burden" for surveys lacks explanation on how fewer respondents might affect survey quality and outcomes.
Terms like "OMB Control Number" and complex procedural jargon may confuse the general public, suggesting a need for clearer explanations.
The inclusion of multiple methods for comment submission, such as hand delivery and mail, may seem outdated. The emphasis on digital submissions could simplify the process for both public participants and the FDIC.
Impact on the Public
Broadly, this document serves an essential role in ensuring that FDIC regulations are both effective and considerate of public and institutional workloads. It holds the potential to refine procedures that banks must follow, directly impacting banking operations and, by extension, services to the public.
Impact on Specific Stakeholders
For banks, especially those under FDIC supervision, feedback could lead to streamlined security compliance processes and improved examination protocols, thus reducing their administrative workload.
For employees and security officers in these institutions, the revised procedures might mean less time spent on paperwork and more on meaningful security and compliance tasks.
For the FDIC itself, the feedback mechanism could enhance its capability to ensure effective regulation implementation without imposing unnecessary burdens.
The opportunity for public comment is crucial for an inclusive regulatory framework that considers the voices of those it affects. However, improving accessibility and transparency in such requests would augment both public engagement and the efficacy of the feedback received.
Issues
• The document does not specify the exact nature of the '9,670-hour decrease in burden' associated with the Procedures for Monitoring Bank Protection Act Compliance. It mentions the elimination of certain respondents and revisions to estimates without detailed breakdown.
• The 'Ombudsman Post-Examination Surveys' section notes a '251-hour decrease in burden' due to reduced respondents, but it lacks specific details about how the reduced number of respondents impacts the results or quality of the surveys.
• The general public may find the technical terms like 'OMB Control Number,' 'FDIC-supervised insured depository institutions,' and references to specific forms difficult to understand without additional explanation.
• The method of submitting comments via hand delivery, email, and mail might be considered outdated, especially given the push for digital methods. While a website link is provided, further emphasis on digital submission might reduce administrative burden.
• The information concerning the burden estimate for each collection is mentioned, but the exact number of hours for each specific respondent group is not detailed, which may cause confusion about the distribution of effort.